Various corresponence from the Citizens for the Protection of Logan Canyon, 1987-1994

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Mr. Dave Berg
Utah Department of Transportation
4501 South 2700 West
Salt Lake City, UT 84119
Dear Mr. Berg,
655 Canyon Road
Logan, UT 84321
August 22, 1994
As a charter member of Citizens for the Protection of Logan
Canyon and a longtime activist on the Logan CanyonlU.S. 89 question,
I have recently had the opportunity to study the preliminary draft of
the Record of Decision. I write now to tell you that in my opinion,
the ROD manifests the same errors and oversights, and the same
fundamental mispapprehension, that so unfortunately characterized
the DEIS and the PElS. •
The basic problem with the ROD is that the purpose and need
for the project have simply not been established. The traffic-flow
projections and th~ safety argument are still being based on deeply
flawed data. The ROD admits problems with the data but goes right
on to assume the essential correctness of all assumptions flowing
from the faulty statistics. Without rigorously collecting and checking
traffic flow data over a period of time, maintaining consistent check
points, how can UDOT make any believable projections of flow for the
future, and how can UDOT present any accident-rate analysis at all?
The fact is that there is no traffic problem in Logan Canyon,
and no particular safety problem other than the slow deterioration of
three bridges.
The ROD skims over this huge and glaring hole in the project's
rationale. It then proceeds to handle the comments, questions, and
opposition of the public with what must be called pure arrogance. To
the very serious objection that no study was ever done on people's
values and perceptions concerning the Canyon, the ROD devotes only
eight dismissive words. To the often-proposed idea of using turnouts
instead of passing lanes, the ROD has no substantive response at all .
To the detailed and specific critiques of UDOT's traffic and safety
numbers, critiques offered by several highly qualified scientists, the
response is simply that UDOT used standard and professional
methods of analysis. This is not a response. To the concept that
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Logan Canyon is as much a destination as a route of travel to
somewhere else, and thus should be treated in a special way, the ROD
simply says the canyon is both a destination and a route, and then
goes ahead to treat it as a route only.
I believe an objective observer must conclude that UDOT has
never truly considered the objections to this project. They only
conducted an EIS when forced to. They hired a consulting firm that,
to judge by the evidence, gave them what they wanted--a green
light. They absolutely ignored overwhelming public opinion against
their "preferred alternative" and in favor of the Conservationists'
Alternative. They continue to use, and possibly abuse, flawed basic
data in order to justify their project. The conclusion appears
inescapable: UDOT wants to build this project, and will let nothing
stand in their way.
If I may offer a suggestion: Issue a ROD on the three bridges
(these have never been a point of contention), and then, while the
bridges are being rebuilt, conduct a genuine Environmental Impact
Statement process and issue a Supplemental EIS on the remainder of
the project.
Sincerely,
Thomas J. Lyon
Dale Bosworth
Supervisor, Wasatch-Cache National Forest
125 South State St.
Salt Lake City, Utah, 84111
Dear Dale:
February 10, 1989
I regret I was unable to attend the meeting concerning the
Logan Canyon Highway Project on February 3. Unfortunately, it was
necessary for me to be out of Logan.
I have read the latest (Jan. 20th) version of
tive for the project, and I am greatly concerned.
alize it in detail here, but only to give you some
the Agency Alterna­I
do not wish to an­general
comments:
1. This is basically the high speed alternative in the preliminary
DEIS. We appear to be just about where we were over two years (and
endless amounts of time and energy) ago.
2. The middle section of the Canyon has been reduced to only 4 miles­from
Right Fork to lower Twin Bridge; we regard the middle section as
the entire distance from Right Fork to Ricks Springs. This redesignation,
with the attendent upgrading of the road to a 35 mph design (probably
50 mph signing) from Twin Bridge to Ricks Springs is unacceptable, since
the consequent environmental damage will be severe.
3. The high speed design of the upper section will result in un­acceptable
environmental impacts, particularly in the Beaver Creek and
Summit sections.
4. There are several safety concerns vlith respect to the placement
of passing lanes, especially in the Dugway and near the Limber Pine
turnout.
5. The implementation of this alternative requires 45 (!) ammend­ments
to the Forest Plan, surely a new worlds record for any forest
plan involving a single project. The cumulative effect of this large
number of ammendments is such that a major change in The Plan will
be required - a revision, with everything that implies. Attempts to
get by with an ammendment will certainly be appealed.
6. The Agency Alternative has little detail, making analysis of
its impacts by citizens not throughly acquainted with both the area and
the previous history almost impossible. If it appears as such in the
EIS, the EIS will be challenged as not meeting NEPA criteria.
7. The cover letter sent with the alternative, bearing the signa­tures
of the three agency engineers, attempts to disclaim the alter­native
as a "preferred" alternative. This is, to say the least, dis­ingeneous.
Any alternative that is endorsed by a Forest Service rep-
presentative is clearly destined to become the "preferred alternative."
I wish to repeat something live said in previous meetings with you: we
accepted the Forest Plan on the assumption it was to be taken seriously
by you. It states, e.g., that liThe road will not be raised to a higher
standard than existing." (Chapter 6, p. 236). Other places in the plan
are clear about maintining the scenic quality of the highway (VQO classi­fication,
e.g.). You have recently designated the highway as a "Scenic
Byway". If the Plan had proposed the kinds of changes found in the Agency
Alternative, it certainly would have been appealed. To abandon the Plan
now, under pressure from UDOT and FHWA, is to break faith with the environ­mental
community and reduce Forest Service credibility to a new low.
cc: Dave Baumgartner
Tom Lyon
Dick Carter UWA
Steve Flint
Bruce Pendery Bridgerland Audubon
Rudy Lukez Utah Chapter, Sierra Club
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S tn+:erely, • -7
Jack T. Spence
Dept. of Chemistry
Utah State University
Logan, Ut 84322
,
tate 0 Samuel J. Taylor
Chai rman
Wayne S. Winters UTAH DEPARTMENT OF TRANSPORTATION Vice Chairman E. H. Findlay
Director
Gene Sturzenegger, P.E.
Assistant Director
H. H. Richardson, P.E.
Disl.ri cl Director
169 North Wall Avenue
P.O. Box 2747
Ogden. Utah 84404
To Whom It May Concern:
James G. Larkin
February 2, 19MaunCox
Todd G. Weston
Elva H. Anderson
Secretary
The attached document is an alternative for improvements to SR-89 in Logan
Canyon. Elements of the alternative have been carefully examined by
representatives of the UOOT, FHWA, and USFS. This document should not be
considered as a preferred alternative, nor as completely addressing impacts of
the suggested elements, but as one alternative of many possible alternatives.
If the environmental impact on an element by element, and total element basis
is acceptable, as analyzed in the environmental impact statement, then the
elements of this alternative should be pursued. This alternative will be
included in the Environmental Impact Statement.
Various groups may wish to meet with agency representatives to discuss this or
other improvement concepts. Arrangements can be made by contacting Lynn
Zollinger at 399-5921.
Richard Harris, P.E.
USFS, Forest Engineer
LRZljw/0924J
an equal opportunity employer
n Silver, P.E.
, Area Engineer
Sincerely yours,
n R. Zo lnger, P. E.
Preconstruction Engineer, 0-1
Dave BaUTIBa:r tner, District Ran er
U .. J . Fores t Service
860 N. 1200 r: .
Logan, UT 84321
Dear Dave:
655 Canyon Road
Logan, tIT 94321
January 17, 1989
Stew Flint provided Ire vlith a ooPY of tJ'1e "agency alternative"
on the Logan Canyon Jigrrway, and. I presume you might t:e interested in
having ccmnents on it.
The dOC1..ltmnt represent:.S no significant change frQ"ll tJDOT' ~' 1979
plans for Logan ('",,'lIlyon. It reflects absolutely none of the I.D. team' s
input, delivered in bA16nty-two meetings, each of several hoUrs' duration.
It reflects no environrrental consciotl."3ness at all, but i s Jasically an
en1]iI1eering statement. It makes the old, thoroughly discredited ar<Jl!frent
ti'.at flattening curves (t.l)ereby increasing speeds) is sorreh<:Hl going to
inprove safety. In sum, this document tal<.es us back to squ8le one in
the whole process. It a.:OlJI1t'3 to a declaration of \iar against the canyon
and against the p...~ple defending it.
'!'he rrost glaring procedural flat., in this OoCllInf'..nt is that it offers
onl y vague inforrration on just ",hat cons truction is contemplated, in
s:pecific places. It defers consideration of specific construction plans
until a later hearing--later than the hearings for the DElS. If I am not
mistaken, this is not )EPA Folicy.
This dccurrent calls for 49 amendments to the Forest Plan. vJhy not be
straightforward about it and say that the Forest Plan, as it applies to
logan Canyon, is totally irreleva.1'1t? The cumulative effect-s of 49
J:nPJ1ts surely add up to a revised Forest Plal1. It seem..g apparent that the
Forest Service has in eff~"Ct ded.ded that Logan canyon i s in fact !'lot any
kind of a special scenic resource i so let's revise the Pla."'1 to reflect the ~ actual assessment of the Forest Service. "
The re-channeling of Eeaver Creek is an enviro11l:!'ental outrage, and I
believe it itlill be seen this TNay by sportsnan's groups as vlell as by anyone
generallv- concerned \vl. th the environi11E:mt. The extraordinary number and of passing lanes in the upl?6r canyon ".,ill silt~)ly invite high spgeds,
t..'1u~ reducing safety. rrh.e three engineers ~'lho drew up t..'1is doCUi1Ent do
not appear to realize that flOvl within a system cannot be faster t.~an its
slCY.Nest single point ~ their plans for Logan Canyon vlOuld have areas of
very high speeds suddenly funneling dO'VTI to areas of lo,..er speeds. This
could be calaITlitous.
I will save deta:i..led <::x::lII'!.rent~ on each mile or tenth of a mile for a
future opportunity. \ t present I will only Sllnmarize by saying that the
ph1.1of'"ophy behind this "agency alt.emative" is only too clear. v"fuat dis­tresses
me alrrost equally with the contemplated envirol1I'l'ental destruct.i.on
is the Forest Service's apparent acquiescence in it.
•
cm· cere1 y ,
Thomas J. Lyon
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R-234
TO
FROM
emoran um·
. Those listed Below • r:
._0'
RECEIVED
MAr 29
UTAH DEPARTMENT OF TRANSPORTATIC1N'987
.CH2M HII.J..
DATE: May 19,~~7
f
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: R. James NaegI' .-, "1!; lnee f
Location and Enviro~ ental Studies J
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SUBJECT: Logan Canyon, u.s.-84 Study
Biological Assessment
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Atta ~ hed is a copy of the Biological Assessment done by
Stanley L. Welsh, Endangered Plant Studies, Inc., of Orem
Utah.
The Maguire Primrose found in the project vicinity is
the object of the Biological Assessment.
If you have questions or comments, please contact John Neil
of our office at 965-4227. Thank you for your cooperation.
RJN/JNeil/ps
Attachment
cc: Robert Ruesink, U.S. Fish & Wildlife
Daniel Dake, FHWA
~~ s.tan .. Nuffer, CH2M Hill
Eduardo Norat, UDOT
John Neil, UDOT
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18 May 1987
ENDANGERED PLANT STUDIES, INC.
129 North 1000 East
Orem, Utah 84057
(80n 225-7085
~lr. James R. Naegle, P.E.
UTAH DEPARTMENT OF TRANSPORTATION
4501 South 2700 West
MAY 1 9 1987
d,I}' . .
Utah Department T ranlpOnallori
Salt Lake City, Utah 84119
Dear Mr. Naegle:
location & Environ. Sludies
This report is in response to your letter of 5 May 1987 delivered to EPS
from the Utah Department of Transportation on 7 May 1987 regarding a
biological assessment of a segment of the highway in Logan Canyon
' (Project No. 1371163, FO; Authority No. 5988).
An on-site survey was conducted during the period May 11-12 on a segment
of the Logan Canyon highway adjacent to and east of the Wood Camp
Trailer Park to the vicinity of milepost 385, a distance of
approximately 1000 feet, and for another 1000 feet east of there to
assure coverage of a second population of of Maguire primrose (no. 5 of
the attached map).
Prior to the on-site survey a literature review was undertaken.
Specific references were sought concerning present knowledge of the
distribution of Primula maguirei, a species listed as threatened under
stipulations of the Endangered Species Act of 1973, as amended.
Literature reviewed included status reports by Welsh in 1979 and the
Utah Native Plant Society (Padgett 1987). The latter report is
sUlmnarized in an Apri 1 1987 report to the Utah Department of
Transportation by CH2M Hill, which was made available by your office.
The Maguire primrose is apparently a calciphile, restricted to Laketown
and Fish Haven dolomite formations. It js likewise a mesophyte, growing
where moisture is available at least through the flowering period, which
apparently is from early April to after mid-May. Plants in more arid
and exposed sites flower first, followed later by those of the more
protected and shaded areas.
Proposed highway modifications, alternatives 81, C1, and D1, were
considered. All are essentially within the area of concern for a
principal population (designated in reports as population 4) of the
Maguire primrose. The plant occurs on outcrops of limestone south of
the highway, beginning at a point approximately 700 feet west of
milepost 385 and extending east to a point approximately 350 feet west
of that milepost. The population, estimated to contain 176 clumps of Maguire primrose (Padgett 1987), • occurs in small aggregations on exposed
boulderlike outcrops at the west edge of the population. The initial
(westernmost) occurrences are about 40 to 50 f'eet above the h , ano
about that same d ~ roa er. rd
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the limestone is exposed as a cliff-forming unit and the population is
largest in the area where it is most exposed to ~h.f= li i,gb!.Jay, • ..aO_Q.u.L ,550 ...
feet west of milepost 38.5_ _ - At that most developed and deeply shaded
exposure the plants occur in profusion, beginning at a point estimated
at about 30 feet above the existing road. Eastward the exposure trends
upward in elevation and the population follows that exposure to perhaps
a hundred feet above the roadway.
The second population in close proximity to the proposed modification
(population 5) begins some 400 or 500 feet to the east of the east end
of the area of concern. The plants are more remote from the highway and
the plants are more scattered. There does not seem to be any potential
impact of the present proposal on that population.
Three other plants were noted in the CH2M Hill report indicated above.
They are Erigeron cronQuistii, Musineon lineare, and Penstemon
compactus. All are currently cited as Category 2 plants in the Federal
Register, indicating that they are possible candidates for future
listing processes. Of these species only MusineQn was noted within the
proposed construction site. The species is a corrnllon component of the
limestone cliffs plant couullunities in Logan Canyon. It is growing with
the Maguire primrose at the population 4 site. The proposed action is
not thought to constitute a significant threat to the Musineon or to the
other category 2 species.
Two concerns were stated in the CH2M Hill report for the Maguire
primrose, especially at population 4. Other populations (2, 3, and 6)
known for the species are considered by me to be too remote from the
construction site as to be threatened by the proposed action. The
concerns involve cold air drainage down Logan Canyon, and the moderating
effect of canyon bottom vegetation on adjacent cliffs serving to buffer
the existing populations of Maguire primrose. To these can be added a
third concern -- dust from construction activities. Dust might overlay
stigmas thus providing competition for pollination and reduced seed set.
err? tu( 'Concern number one, cold air drainage, does not seem to be significant.
The draina e of cold air is expected to continue atGUt- as in the pasf ,
regardless of highway modifications. The second concern is probably
more lmportar.t, but, it s 0 rd be 0 ed, that the best developed part of
the population of Maguire primrose at pop~lation 4 is on the most =7
exposed portion of the cliff system (i.e., there is little or n~ ~
screening ve etetation betwe e 0 ulation....and-the road). _However,
I in pow of action all possible care should be given to preventiOn of
wholesale removal of the remaining screening vegetation. Only that part
of the canyon bottom vegetation apsolutely in the way of_construction
should be removed. The third concern, dust, can be mitigated by waiting
until the flowering period is over prior to corrmencement of construction
activities, i.e., construction should commence no earlier than June.
"-------
The nearest approach of the construction is at the bend of the road at
the westernmost edge of the population 4 site. It is understood that as
much as 10 feet of the toe of the• ridge might have to be removed to
allow proper alignment of the roadway. This sho~ld cause no problem to
the PQ,Qulation if the rockwork is dertaken I-lith s~re. Blasting shou ld
be kept at a minimum and proper barriers constructed as to prevent
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uphill scattering o-f -debris.- -
If the recommendations cited above are followed there should be minimal ,
or no 'mpiilc-t- to- the_Magui re primrose PQpulation 4. The other
populations will not be adversely affected.
With best regards,
Sincerely yours,
, .
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Portion Mount Elmer
quajrangle map s~owing
of the 7.5
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the approximate boundaries of
populations 2, 3, 4, 5, and 6.
47'30"
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Dear Dave,
45 ~~ - 400
Logan, UT
W
S4321
24 .January, 1989
Since we last t<11ked, Lynn Zollineer has given us the opportunity
to reviJe the conservationist's proposal. We have decided to take
advBn tage of tLi s oH)ortuni ty. 'Nhi Ie we do not plan 8 Y1.y maj or change s
in our plan of a year and a half ago, this will p€rmit us to
rc: sp~nd once again wi th our cOIJ.Jerns over UDO'l" s al-'parent preferred
a 1 terYla ti ve. We can a Iso update t he few 10ca ti ons w!lere thin["s
have eh8.nged.
As I m enti~n ed last week, the agency altel~ative seems to be the
D alter~ ative fer all except 4 miles. We share your concerns ttat
the environmental analysis w!lich we have seen is weak. The desires
of UDCT to put much of this (eg. rubble disI)osal) off un. til the
"design hearings" is particularly worri some.
We will be in touch when we produce this reviseo draft. If UDCT
would be willing to meet with us now we can once again try to
expl.ain our concerns.
Sincere1..y,
/U~ 2-:-e~:r
• Steve Flint
Copies: Tom 1,";on /
Jacij:k"S pence • B'ruce Pendery
P. S. It is also disappointing to note that, despite the national
recognition which the Forest Service has given to the scenic
qualities of Logan Canyon, UDOT has put off all ~ention of
turnouts until the design hearings. I worry thc:.t "Sight distance
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and tapers" will be difficult to include, so we will end up
with no turnouts.
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Dear Dave:
T .!.n responee
--In general t his plan
1/20/69
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•
•
Editor, The Herald Journal
75 W 300 N
Logan, Utah 84321
Dear Sir:
January 22, 1988
As a member of the 10 team responsible for preparation of tech­nical
information for the Logan Canyon highway project EIS, I am
appalled at the recent decision by UDOT to pursue the maximum de­velopment
alternative.
If this alternative is implemented, most of the canyon from
Right Fork to Ricks Springs (as well as major sections of the up­per
canyon) will be severely affected. Much of the free running
river will be channeled within retaining walls, the river bed it­self
will be altered, the riparian zone (on which the wildlife
depends) will be destroyed, the fishing and water quality will
be degraded, the river will disappear beneath cantilever structures,
the lovely riv~rside rock ledges will by dynamited, huge cuts .
in the hillsides will be made, thousands of cubic yards of fill
will be dumped into side canyons, large amounts of conifer forest
and other vegetation will be bulldozed and Logan Canyon as we
now know it will be gone forever.
UDOT has made this decision in spite of the overwhelming pub­lic
opposition to this alternative expressed in the scoping meet­ings,
in spite of a legally binding Forest Service Plan which des­ignates
Logan Canyon as a scenic highway and prohibits the destruc­tion
consequent to the project, and in spite of the best efforts
of environmental representatives on the 10 team in endless meet­ings
over more than two years to achieve a reasonable compromise
which protects the canyon and also allows necessary improvements.
In fact, the UDOT decision prepresents a no compromise position,
essentially identical to their position in 1980. In short, UDOT.
in their incredible arrogance, has listened to no one and has
learned nothing. Two years or work and over $600,000 of taxpayers
money have been wasted. Preservation of the scenic beauty and the
environmental quality of Logan Canyon is of no apparent concern
to this public agency.
Many people have asked me what they can do to protect the can­yon.
Telephone calls and letters to James Naegle, Utah Department
of Transportation, 4501 South 2700 West, Salt Lake City, 84119
protesting the decision, and to Dave Baumgartner, U.S. Forest Ser­vice,
860 N 1200 E, Logan supporting the Forest Service Plan are
needed. Later, there will be an opportunity for both oral and
written comments when the DEIS is released. Additional infor­mation
may be obtained by calling 753-8548. Only a concerned
citizenry can preserve Logan Canyon from the mindless destruc-tion
planned for it by UDOT.
Jack T. Spence
361 Blvd
Logan, Ut 84321
-
•
Mr. James Naegle
Utah Department of Transportation
4501 So. 2700 West
Salt Lake City, Utah 84119
Dear Jim:
January 11, 1988
Thank you for your recent letter concerning my efforts in the
Logan Canyon DEIS study.
While I appreciate your comments, I find them inconsistent with
your actions. After spending the better part of two years attend­ing
meetings, reading documents, checking calculations, etc., I con­sider
it an insult not to be provided with a copy of the preliminary
DEIS. It cost us (Sierra Club, Audubon Society, Utah Wilderness
Association) $20.00 to duplicate the Forest Service copy, which I
understand was made available to us only reluctantly and at the in­sistence
of the Forest Service. So much for the good faith of UDOT.
I also wish to make some comments on the role of the 10 team
in this study. It was agreed early on that all technical memos
would be approved by the team. This has not been done. It was
my understanding the DEIS would be approved by the team. This is
clearly not to be done. Finally, it was also my understanding the
10 team would make recommendations concerning a preferred alter­native.
Again, this is clearly not to be done. I regard this as
a breach of faith by both UDOT and CH2M Hill.
The preliminary DEIS has several major problems:
1.The Spot Improvement Alternative must be considered as en­compassing
all 35 spot improvements. It is a violation of NEPA
requirements to present a shopping list, with UDOT selecting some
number of improvements from the list at a later date.
2.In view of this, there is no environmentally acceptable
alternative in the preliminary DEIS except No Action.
3.NEPA requirements have not been met with respect to a range
of alternatives. The Spot Improvement alternative with all 35
projects at the level described is essentially the same as Alter­native
C.
Unless our alternative (now in the Appendix), or a reasonably
similar alternative, is included as a legitimate alternative, we
will oppose all alternatives except No Action, or request that the
DEIS be rejected as not meeting NEPA requirements. Legal action
with respect to this request may also be pursued.
I regret the culmination of two years of effort has resulted
in this situation. The environmental representatives on the 10.
team have repeatedly tried to convince UDOT and CH2M Hill that
their concerns need serious attention. It is clear we have failed.
and the present situation must be regarded as adversary.
cc:Dale Bosworth
Dave Baumgartner
Lynn Zo 11 i nger
Stan Nuffer
UWA
Rudy Lukez, Sierra Club
Steve Flint, Audubon Society
Sincerely,
/;"1, ~--:
,"?? ,CI?;/ .
;
/ .
/ Jack T. Spence
v ' 361 Blvd.
Logan, Ut 84321
• • • I Izens or e ·ro ec Ion
o oan _an on
rh.J () ~ £ //-J r .
Wilson
Lcs+ -f,~ r Tc, /k.e..A fa J.. ~ ~ ~
From: Steve Flint ~~-k .:'5!/{<-;f­He:
~gan Canyon highway project
21 September, 1987
ret ... -eJfe.-/ 1-4 f-€>e-J;
·~ e ...,
Of
F..nclosed are the ~errestrial Resources Technical Memorandum and
the biological assessment for Primula maguirei. This biological
assessment is referred to in the tech. memo as "Welsh 1987".
One of the most glaring faults of this tech. memo is the failure
to adequately discuss the disposal of waste material. Table 2 (p. 21)
lists a few locations (but does not address impacts), but does not
admit that these locations will only accolnodate a small portion of
the waste which the action alternatives will generate. CH2MHill's
refusal to discuss site-specific impacts contributes to this problem.
Table 1 (p. 18) shows the high percentage of the riparian zone
which would be impacted. Most of this impact would be retaining walls
at the edge of tl1e river, destroying all vegetation on one side of
the stream.
This document downplays the impacts on P. maguirei. One of our
concerns, which is not mentioned in this document, is the proposed
location of & slow vehicle turnout adjacent to population 4. We believe
this location is unacceptable as it would remove too much vegetation.
In addi tion, there is a "collection" danger: the primrose is attractive
1IIlhl?n it blooms in the sprine:. We fear people may not know of its
status and attempt to remove plants for their gardens. A related
problem is the display of papulation locations in Figure 1 (p. 8) •
We believe this is proprietary information which should not be included
in a document such a3 this which is available to the public. Much of it
is not even necessary for this study: populations 2 and 6 are outside
the study area, and population 3 is across the river from the highway.
The biological assessment dismisses the impacts to the primrose
by speculating on its physiologival performance. It should be pointed
out that nothing is known about the species' physiology; all the
speculation is based on its habitat. In addition, while the author
(Welsh) has considerable experience in taxonomy, I do not believe he
has much background in physiology.
Other tech. memos will follow shortly.
Note: Despite the fact CH2MHill had provided UDOT with a
draft of the EIS, they have not produced a final
version of the Terrestrial Resources tech. memo.
This June '37 version is the most recent draft.
p.o. box 3580 logan, ut 84321
•
• • -
Citizens for the Protection of Logan Canyon
P. O. Box 3451, Logan, Utah 84323 - 3451
April 5, 1995
Citizens for the Protection of Logan Canyon on
Thursday, March 30, 1995, filed a lawsuit against
Cache County and its County Council for not complying with the laws of the State of
Utah and the ordinances of Cache County when they issued a Special Permit to the
Westons permitting their sign in Wellsville Canyon. As an organization and as
individuals, CPLC has a long-standing interest in Cache County and its canyons. It is the
sentiment of the organization that permitting the sign, in direct violation of state and
county laws, set a dangerous precedent for Logan Canyon, as well as for all of the
canyons in the county.
Business signs are presently prohibited in Forest/Recreation Zones under the current
County Land Use Ordinances. Application for a Special Permit for the sign was first
submitted to the Cache County Planning Commission, which unanimously recommended
against the proposed sign because it was not in keeping with the Forest/Recreation Zone.
The Planning Commission suggested an alternative more in keeping with the Zone. The
County Council, which in the Ordinances has reserved to itself the final decision, granted
a Special Permit for the sign, which, in the meantime, had already been erected by the
Westons without a permit.
By filing this lawsuit, CPLC hopes to make certain that all county agencies follow legal
procedures when making decisions about public lands, including all canyons within
Forest/Recreation Zones.
CPLC could use your help in defraying the expenses of this lawsuit. If you have not sent
in your membership dues, please take this opportunity to do so. Or, if you are already a
member of CPLC, please consider making an additional contribution.
--------------------------------------------------------------------------------------------------------------------
please print legibly
CPLC MEMBERSHIP APPLICATION
Name Address ----------------------------- City State Zip Phone: Hom e ___ Work ___ _
Areas of Expertise/ Willingness to Volunteer __________________________________ Regular Member ($10) Student Member ($5)-:--_
I wish to make an additional contribution of: $10 $25 $50_ $100_
Other --
Send to: CPLC, P.O. Box 3451, Logan, UT 84323-3451
•
,
•
-, ,
Mr. David W. Berg P.E.
Chief Environmental Engineer
Utah Department of Transportation
4501 South 2700 West
Salt Lake City, UT 84119
Dear Mr. Berg:
Citizens for the Protection
of Logan Canyon
P.O. Box 3501
Logan, UT 84323
October 27, 1994
With our thanks to you personally for your willingness to hear our
case, and our appreciation for being included in the process of
modifying the Logan Canyon ROD, we wish to communicate our
provisional and conditional approval of the revised ROD. Specifically,
this approval refers to agreements between UDOT and representatives
of CPLC, arrived at in meetings taking place from December, 1993,
through October, 1994, as to what the final Logan Canyon ROD should
contain. We understand and accept the "quid pro quo" nature of those
negotiations, and the following represents the present CPLC position.
General Issues of Utmost Concern to CPLC:
(1) With the exception of the need for replacing bridges, CPLC is not
persuaded that the project's overall purpose and need have been
demonstrated.
(2) CPLC remains concerned with the accuracy and statistical reliability
of both traffic-flow and safety data collected by UDOT. Before CPLC
could agree to any accident-dependent curve-flattening (for example,
curve #5 in Section 1a), the organization, as part of the CAT team, would
need to study the data being presented.
(3) CPLC restates its deep concern for the protection of any and all
wetlands and riparian areas along the project route, and its concern for
the longterm disposition of these sites.
(4) CPLC restates its deep concern for the intactness of the visual and
aesthetic resources of Logan Canyon, and restates its support of the
Wasatch-Cache National Forest's Forest Plan of 1985, which states that
there shall be no degradation of the Canyon's visual resource.
•
•
CPLCIUDOT
October 27, 1994
p. 2
(5) CPLC strongly supports the hiring of an independent consultant, to
be actively engaged in the design and construction phases of the project,
and to have site-specific stop-work powers during construction. CPLC
strongly supports the preparation of a detailed monitoring plan by
UDOT, which will spell out the qualifications, independence, and range of
specific powers of the consultant and the consultant's team, and will
detail the frequency and length of time of on-site inspections.
Point-by-Point Discussion:
[The following are specific issues of demonstrated concern to CPLC
members. Other issues may arise during the project's design phase.]
A. Roadway Widths
(1) CPLC understands that the roadway width from the beginning
of Section 1 a to Lower Twin Bridge will be 26', and the roadway width
from Lower Twin Bridge to the end of Section 1b will be 34'.
(2) CPLC understands that the roadway width in the Lower
Upper Canyon -- specifically, from the cattle guard at Milepost 391.6 to
the Beaver Mountain turnoff -- will be 34'.
(3) CPLC remains concerned with the projected 40' roadway
width from Beaver Mountain turnoff to the Bear Lake Overlook.
B. Alignment
(1) CPLC continues to question the need for realignment of curves
in the project.
(2) CPLC strongly supports the present alignment for Curve #5 in
Section 1a.
(3) CPLC supports the proposed northern alignment for Curve #85.
C. Passing Lanes
(1) CPLC supports the use of slow-vehicle turnouts as preferable
to passing lanes, specifically through Section 2. CPLC remains concerned
with the number, location, and length of passing lanes proposed by
UDOT in Section 2.
D. Bridges
(1) CPLC understands that bridge replacement will the first
construction undertaken in the project.
'.
•• 0 ' , . •
E. Riprap and Retaining Walls
CPLCIUDOT
October 27, 1994
p. 3
(1) CPLC strongly supports minimizing all uses of riprap and
retaining walls. Natural banks should be retained wherever possible.
F. Location of the Batch Plant
(1) CPLC recognizes the complexity of environmental trade-offs
involved in the location of a batch plant for each specific phase of the
overall project. However, CPLC strongly supports the use of one batch
plant, located at the state equipment sheds, for all phases of the project.
G. Future Activity of CPLC
(1) CPLC looks forward to participating on the CAT team during
the design and construction phases.
(2) CPLC reserves its normal constitutional right to seek legal
redress in the event of noncompliance with the revised ROD, violation of
environmental law, or noncompliance with the 1985 Wasatch-Cache
Forest Plan. . ..
Mark Bowen
Nathan Hult
Thomas Lyon
--- - ----------
Sean Swaner
Sincerely,
The Steering Committee
Citizens for the Protection of Logan Canyon
Katherine Gilbert Christine Hult
Lauren Keller Ronald Lanner
Paul Packer Gordon Steinhoff
.' .'
Mr. David W. Berg P.E.
Chief Environmental Engineer
Utah Department of Transportation
4501 South 2700 West
Salt Lake City, UT 84119
Dear Mr. Berg:
Citizens for the Protection
of Logan Canyon
P.O. Box 3501
Logan, UT 84323
October 27, 1994
With our thanks to you personally for your willingness to hear our
case, and our appreciation for being included in the process of
modifying the Logan Canyon ROD, we wish to communicate our
provisional and conditional approval of the revised ROD. Specifically,
this approval refers to agreements between UDOT and representatives
of CPLC, arrived at in meetings taking place from December, 1993,
through October, 1994, as to what the final Logan Canyon ROD should
contain. We understand and accept the "quid pro quo" nature of those
negotiations, and the following represents the present CPLC position.
General Issues of Utmost Concern to CPLC:
(1) With the exception of the need for replacing bridges, CPLC is not
persuaded that the project's overall purpose and need have been
demonstrated.
(2) CPLC remains concerned with the accuracy and statistical reliability
of both traffic-flow and safety data collected by UDOT. Before CPLC
could agree to any accident-dependent curve-flattening (for example,
curve #5 in Section la), the organization, as part of the CAT team, would
need to study the data being presented.
(3) CPLC restates its deep concern for the protection of any and all
wetlands and riparian areas along the project route, and its concern for
the longterm disposition of these sites.
(4) CPLC restates its deep concern for the intactness of the visual and
aesthetic resources of Logan Canyon, and restates its support of the
Wasatch-Cache National Forest's Forest Plan of 1985, which states that
there shall be no degradation of the Canyon's visual resource.
. - -
CPLClUDOT
October 27, 1994
p. 2
(5) CPLC strongly supports the hiring of an independent consultant, to
be actively engaged in the design and construction phases of the project,
and to have site-specific stop-work powers during construction. CPLC
strongly supports the preparation of a detailed monitoring plan by
UDOT, which will spell out the qualifications, independence, and range of
specific powers of the consultant and the consultant's team, and will
detail the frequency and length of time of on-site inspections.
Point-by-Point Discussion:
[The following are specific issues of demonstrated concern to CPLC
members. Other issues may arise during the project's design phase.]
A. Roadway Widths
(1) CPLC understands that the roadway width from the beginning
of Section 1 a to Lower Twin Bridge will be 26', and the roadway width
from Lower Twin Bridge to the end of Section 1 b will be 34'.
(2) CPLC understands that the roadway width in the Lower
Upper Canyon -- specifically, from the cattle guard at Milepost 391.6 to
the Beaver Mountain turnoff -- will be 34'.
(3) CPLC remains concerned with the projected 40' roadway
width from Beaver Mountain turnoff to the Bear Lake Overlook.
B. Alignment
(1) CPLC continues to question the need for realignment of curves
in the project.
(2) CPLC strongly supports the present alignment for Curve #5 in
Section 1a.
(3) CPLC supports the proposed northern alignment for Curve #85.
C. Passing Lanes
(1) CPLC supports the use of slow-vehicle turnouts as preferable
to passing lanes, specifically through Section 2. CPLC remains concerned
with the number, location, and length of passing lanes proposed by
UDOT in Section 2.
D. Bridges
(1) CPLC understands that bridge replacement will the first
construction undertaken in the project.
•
E. Riprap and Retaining Walls
CPLCIUDOT
October 27, 1994
p. 3
(1) CPLC strongly supports minimizing all uses of riprap and
retaining walls. Natural banks should be retained wherever possible.
F. Location of the Batch Plant
(1) CPLC recognizes the complexity of environmental trade-offs
involved in the location of a batch plant for each specific phase of the
overall project. However, CPLC strongly supports the use of one batch
plant, located at the state equipment sheds, for all phases of the project.
G. Future Activity of CPLC
(1) CPLC looks forward to participating on the CAT team during
the design and construction phases.
(2) CPLC reserves its normal constitutional right to seek legal
redress in the event of noncompliance with the revised ROD, violation of
environmental law, or noncompliance with the 1985 Wasatch-Cache
Forest Plan. . --
Mark Bowen
Nathan Hult
Thomas Lyon
-- -- ---------
Sean Swaner
Sincerely,
The Steering Committee
Citizens for the Protection of Logan Canyon
Katherine Gilbert Christine Hult
Lauren Keller Ronald Lanner
Paul Packer Gordon Steinhoff
[DRAFT]
Mr. David W. Berg P.E.
Chief Environmental Engineer
Utah Department of Transportation
4501 South 2700 West
Salt Lake City, UT 84119
Dear Mr. Berg:
Citizens for the Protection
of Logan Canyon
P.O. Box 3501
Logan, UT 84323
October 20, 1994
With our thanks to you personally for your willingness to hear our
case, and our appreciation for being included in the process of
modifying the Logan Canyon ROD, we wish to communicate our
provisional and conditional approval of the revised ROD. Specifically,
this approval refers to agreements between UDOT and representatives
of CPLC, arrived at in meetings taking place from December, 1993,
through October, 1994, as to what the final Logan Canyon ROD should
contain. We understand and accept the "quid pro quo" nature of those
negotiations, and the following represents the present CPLC position.
General Issues of Utmost Concern to CPLC:
(1) CPLC is not persuaded that the project's overall purpose and need
have been demonstrated.
(2) CPLC remains concerned with the accuracy and statistical reliability
of both traffic-flow and safety data collected by UDOT. Before CPLC
could agree to any accident-dependent curveMflattening (for example,
IS iff ~edicni: 1a), the organization, as part of the CAT team, would
Hud "' "tidy the data being presented.
(~, ClYte testates its deep concern for the protection of any and all
\f,t1flnd8 tiiid riparian areas along the project route, and its concern for
th' imtgtefm disp()jition of these sites.
(4) CftLC restat~s its deep concern for the intactness of the visual and
ae~thede res911tc~~ of Logan Canyon, and restates its support of the
Wa§a·t~h-Ca£he National Foreses Forest Plan of 1985, which states that
there shall b~ no degradation of the Canyon's visual resource.
(5) CPLC stroftlly iiUppOtts the hiring of an independent consultant, to
be ~eHv"l)' enga86td ifi the design and construction phases of the project,
iUld to tUlve ~ite"specific stop .. work powers during construction.
Point-by-Point Discussion:
CPLC/UDOT
October 20, 1994
p.2
[The following are specific issues of demonstrated concern to CPLC
members. Other issues may arise during the project's design phase.]
A. Roadway Widths
(1) CPLC understands that the roadway width from the beginning
of Section 1 a to Lower Twin Bridge will be 26', and the roadway width
from Lower Twin Bridge to the end of Section 1 b will be 34'.
(2) CPLC understands that the roadway width in the Lower
Upper Canyon -- specifically, from the cattle guard at Milepost 391.6 to
the Beaver Mountain turnoff -- will be 34'.
(3) CPLC remains concerned with the projected 40' roadway
width from Beaver Mountain turnoff to the Bear Lake Overlook.
B. Alignment
(1) CPLC strongly supports the present alignment for Curve #5 in
Section 1a.
(2) CPLC supports the proposed northern alignment for Curve
#85.
(3) CPLC continues to question the need for realignment of curves
in the project.
C. Passing Lanes
(1) CPLC supports the use of slow-vehicle turnouts as preferable
to passing lanes, specifically through Section 2. CPLC remains concerned
with the number, location, and length of passing lanes proposed by
UDOT in Section 2.
D. Riprap and Retaining Walls
(1) CPLC strongly supports minimizing all uses of riprap and
retaining walls. Natural banks should be retained wherever possible.
E. Location of the Batch Plant
". (1) CPLC recognizes the complexity of environmental trade-offs
involved in " the location of a batch plant for each specific phase of the
overall project. However, CPLC strongly supports the use of one batch
plant, located at the state equipment sheds, for all phases of the project.
F. Future Activity of CPLC
CPLCIUDOT
October 20, 1994
p. 3
(1) CPLC looks forward to participating on the CAT team during
the design and construction phases.
(2) CPLC reserves its normal constitutional right to seek legal
redress in the event of noncompliance with the revised ROD, violation of
environmental law, or noncompliance with the 1985 Wasatch-Cache
Forest Plan.
[signed]
Peter W. Karp
Forest Superv•l sor
Wasatch-Cache National Forest
Mr. Karp,
We are writing to you to request a rev iew of a previous
decision by the Wasatch-Cache National Forest. Recently, you
ammended the Wasatch-Cache National Forest Land and Resource
Ma¢hagement Plan to provide interim protection to the Stillwater
Fork for possible inclusion in the nation's Wild And Scenic River
System.
It is our opinion that both we and your River Inventory Team
believe that at least one river segment on the Cache National
Forest, and probably two, should be eligible as a "recreational"
river under the national Wild and Scenic Rivers Act. These
segments are the Logan River (Lower Twin Bridge to Beaver Ck.)
and the Right Hand Fork of the Logan River. There is currently a
proposed improvement of u.S. 89 by the Utah Department of
Transportation (UDOT). The proposed improvement might harm the
river's flee-flowing nature. Therefore it is important to
consider the Logan River (Lower Twin Bridge to Beaver Creek) now,
before said construction takes place.
We have evaluated this segment o f the Logan and found it is
free-flowing and outstandingly remarkable (see attached
documents). Your wild and Scenic River Inventory Team appears to
agree with us on the latter point. Consult Appendix D of the
recently amended Forest Plan. You will find that the
Identification Team (IDT) found this segment might possess
outstandingly remarkable characterists in five (5) categories.
The IDT found the Stillwater Fork, which you set aside for
interim protection, might possess outstandingly r emarkable
characteristics in only one category.
The problem may be that the IDT did not conside r the segment
free from roads because the Scenic Byway, U.S. 89, parallels the
river along this segment. However, we would call your attention
to the section of the Wild and Scenic Rivers Act for assessing
the free-flowing nature of a recreational river, it states,
"roads may parallel the river for much of its length as long as
much of the road is unobtrusive or well-screened."
We request that you and your Identification Team reconsider
this segment of the Logan. We would prefer assessments of the
Logan from the source to Beaver Ck., Lower Twin Bridge to Beaver
Ck., the Right Hand Fork of the Logan R., and Beaver Ck. (source
to Logan R.). We believe all of these segments may qualify as
recreational rivers under the national Wild and Scenic Rivers
Act.
Sincerely,
Citizens for the
Protection of
Logan Canyon
Mr. Stan "luffer
CH 2
M I-'ill
Box 8748
Boise, ID 83707
Dear Stan:
655 Canyon Road
Logan, UT 84321
June 23, 1987
First, thank you for this opportunity to comment on the drafts
of the technical memoranda and alternatives for the Logan Canyon DEIS.
I consider this a genuine opportunity to (possibly) save a great deal
•
of many people's time and energy. If the DEIS reflects these memoranda,
in content and bias, I think I can assure you there will be an extremely
strong public protest.
As was mentioned yesterday at the meeting in Brigham City, the chief
problem with the memoranda, with the exception of the one on aquatic
resources~ is their very obvious bias toward a major road project. For
example, the socioeconomic memo devotes many pages to the dependence of
Rich County upon Logan for various goods and services. The clear thesis
of this document is that an "improved" road through Logan Canyon is vital
to Rich County':s continued life and to its future development--at one point
even industrial development is mentioned as a future possibility for Rich
County, on the assumption that an "improved" Logan Canyon highway would
make such a thing possible. The fact is that Rich County exists and has
existed without serious hindrance caused by the two-minutes-slower Logan
Canyon highway of the present. The assumption that some kind of industrial
development would be good for Rich County is rank speculation, and judging
from the experience of ' places like Evanston and Rock Springs, is untrue.
But to set this kind of chamber-of-commerce dreaminess forth as a real
item of probability, in a technical memo, is nonsense.
It is also highly biased. We are all aware of the number and strength
of the comments given at the Logan scoping meeting. But these comments DO
NOT APPEAR IN ANY FORM AND ARE NOT REFERENCED ANYWHERE in the documents
supplied so far. They have been completely ignored. The memo on visual
resources is a strange effort to quantify perception and aesthetics, and
results only in fragmenting and obfuscating the real situation into a bunch
of numbers. The fact is that the natural appearance of Logan Canyon is,
along with the ecological health of the river, the absolute primary matter
in hand. I can assure you that perception and the aesthetic sense are not
satisfied by numbers--they are based in an entirely different mode of
awareness.
This brings me to what may be the central problem in documents of this
nature. They attempt to state qualitative issues in quantitative terms.
A wise man once said that to do this is like judging the "Mona Lisa" by
weighing the paint. In the present documents, it is blithely stated that
if native trout are killed by construction, well then we can plant some
Stan Nu ffer
June 23, 1987
page 2
hatchery rainbows "to supplement angler catch rates," [po 38] and everything
will presumably be all right. But this is not so. There is a very great and
widely perceived difference between fishing for wild trout and fishing for
stocked trout; as a matter of fact, this very difference is the basis for the
Logan River's attractiveness as a qual tty trout stream. And it is a primary
reason for the Logan River's being a "million-dollar" fishery. This difference
between quality and quantity cannot be mitigated. It is a basic fact of
existence.
In the same way, you cannot mitigate a road-cut across a hillside. It is
simply there, and it destroys the wholeness of the scene which arouses the
qualitative sense of beauty. This is what the people in the Logan scoping
meeting were trying to say, one after the other. The issues are beauty and
wholeness. You can't fragment these things into a bunch of numbers and expect
people to be satisfied, just as you can't substitute a flabby hatchery fish,
raised on food pellets and habituated to a looming human figure bringing food,
for a wild and wary trout in a natural stream.
The documents presented so far clearly indicate that none of the alternatives
preserves Logan Canyon. "Spot Improvements" was supported by a number of
people at the Logan meeting, including mysel f; but now "Spot Improvements" has
ballooned into a major realignment of the highway in several crucial and
environmentally sensitive sections, and cannot be supported any longer. It
is decidely misleading, and even deceptive, to place "Spot Improvements" next
to "No Action," because it is emphatically not the second-least-damaging
alternative. .
The documents presented so far are biased individually and in the
aggregate. For just one example, "Aquatic Resources" mentions millions of
dollars being spent on the Logan River by fishermen, but this money somehow
does not appear in the socioeconomic memo. Why not? (If we get down to arguing
dollars and cents, which again is not the central issue here, I wonder if all
the alleged Rich County dependence on Logan amounts to a sum comparable to that
spent by Logan River fishermen.) For another example, which appears again and
again throughout the documents, it is alleged that the present highway is unsafe
and that flatter curves and higher speeds would be safer. No documentation for
this assumption is ever presented, and my conclusion is that if there were any
such documentation in existence, it would have been brought forward very
prominently by now. I doubt that a wider, faster, flatter-curved road is any
safer than a narrow, slow, curvy one. People adjust their speed to the circum­stances.
Logan Canyon is a canyon; it cannot be made into something other than
a canyon. If there is a road in it, it will need to be a narrow and winding
road and people will have to drive at slower speeds on it. That's IF the
intactness and beauty of the canyon are to be saved.
I realize that your firm has spent a good deal of time and work on this
matter, and so I hesitate to say the following. But it is clear that the entire
set of documents needs to be redone and written without bias. The "Alternatives"
chapter is so biased as to be for all intents and purposes worthless; it too
needs to be entirely redone. "Spot Imp IOvements" in particular is a travesty.
Sincerely yours,
rhvmAA
Thomas J. Lyon

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•
Mr. Dave Berg
Utah Department of Transportation
4501 South 2700 West
Salt Lake City, UT 84119
Dear Mr. Berg,
655 Canyon Road
Logan, UT 84321
August 22, 1994
As a charter member of Citizens for the Protection of Logan
Canyon and a longtime activist on the Logan CanyonlU.S. 89 question,
I have recently had the opportunity to study the preliminary draft of
the Record of Decision. I write now to tell you that in my opinion,
the ROD manifests the same errors and oversights, and the same
fundamental mispapprehension, that so unfortunately characterized
the DEIS and the PElS. •
The basic problem with the ROD is that the purpose and need
for the project have simply not been established. The traffic-flow
projections and th~ safety argument are still being based on deeply
flawed data. The ROD admits problems with the data but goes right
on to assume the essential correctness of all assumptions flowing
from the faulty statistics. Without rigorously collecting and checking
traffic flow data over a period of time, maintaining consistent check
points, how can UDOT make any believable projections of flow for the
future, and how can UDOT present any accident-rate analysis at all?
The fact is that there is no traffic problem in Logan Canyon,
and no particular safety problem other than the slow deterioration of
three bridges.
The ROD skims over this huge and glaring hole in the project's
rationale. It then proceeds to handle the comments, questions, and
opposition of the public with what must be called pure arrogance. To
the very serious objection that no study was ever done on people's
values and perceptions concerning the Canyon, the ROD devotes only
eight dismissive words. To the often-proposed idea of using turnouts
instead of passing lanes, the ROD has no substantive response at all .
To the detailed and specific critiques of UDOT's traffic and safety
numbers, critiques offered by several highly qualified scientists, the
response is simply that UDOT used standard and professional
methods of analysis. This is not a response. To the concept that
•
Logan Canyon is as much a destination as a route of travel to
somewhere else, and thus should be treated in a special way, the ROD
simply says the canyon is both a destination and a route, and then
goes ahead to treat it as a route only.
I believe an objective observer must conclude that UDOT has
never truly considered the objections to this project. They only
conducted an EIS when forced to. They hired a consulting firm that,
to judge by the evidence, gave them what they wanted--a green
light. They absolutely ignored overwhelming public opinion against
their "preferred alternative" and in favor of the Conservationists'
Alternative. They continue to use, and possibly abuse, flawed basic
data in order to justify their project. The conclusion appears
inescapable: UDOT wants to build this project, and will let nothing
stand in their way.
If I may offer a suggestion: Issue a ROD on the three bridges
(these have never been a point of contention), and then, while the
bridges are being rebuilt, conduct a genuine Environmental Impact
Statement process and issue a Supplemental EIS on the remainder of
the project.
Sincerely,
Thomas J. Lyon
Dale Bosworth
Supervisor, Wasatch-Cache National Forest
125 South State St.
Salt Lake City, Utah, 84111
Dear Dale:
February 10, 1989
I regret I was unable to attend the meeting concerning the
Logan Canyon Highway Project on February 3. Unfortunately, it was
necessary for me to be out of Logan.
I have read the latest (Jan. 20th) version of
tive for the project, and I am greatly concerned.
alize it in detail here, but only to give you some
the Agency Alterna­I
do not wish to an­general
comments:
1. This is basically the high speed alternative in the preliminary
DEIS. We appear to be just about where we were over two years (and
endless amounts of time and energy) ago.
2. The middle section of the Canyon has been reduced to only 4 miles­from
Right Fork to lower Twin Bridge; we regard the middle section as
the entire distance from Right Fork to Ricks Springs. This redesignation,
with the attendent upgrading of the road to a 35 mph design (probably
50 mph signing) from Twin Bridge to Ricks Springs is unacceptable, since
the consequent environmental damage will be severe.
3. The high speed design of the upper section will result in un­acceptable
environmental impacts, particularly in the Beaver Creek and
Summit sections.
4. There are several safety concerns vlith respect to the placement
of passing lanes, especially in the Dugway and near the Limber Pine
turnout.
5. The implementation of this alternative requires 45 (!) ammend­ments
to the Forest Plan, surely a new worlds record for any forest
plan involving a single project. The cumulative effect of this large
number of ammendments is such that a major change in The Plan will
be required - a revision, with everything that implies. Attempts to
get by with an ammendment will certainly be appealed.
6. The Agency Alternative has little detail, making analysis of
its impacts by citizens not throughly acquainted with both the area and
the previous history almost impossible. If it appears as such in the
EIS, the EIS will be challenged as not meeting NEPA criteria.
7. The cover letter sent with the alternative, bearing the signa­tures
of the three agency engineers, attempts to disclaim the alter­native
as a "preferred" alternative. This is, to say the least, dis­ingeneous.
Any alternative that is endorsed by a Forest Service rep-
presentative is clearly destined to become the "preferred alternative."
I wish to repeat something live said in previous meetings with you: we
accepted the Forest Plan on the assumption it was to be taken seriously
by you. It states, e.g., that liThe road will not be raised to a higher
standard than existing." (Chapter 6, p. 236). Other places in the plan
are clear about maintining the scenic quality of the highway (VQO classi­fication,
e.g.). You have recently designated the highway as a "Scenic
Byway". If the Plan had proposed the kinds of changes found in the Agency
Alternative, it certainly would have been appealed. To abandon the Plan
now, under pressure from UDOT and FHWA, is to break faith with the environ­mental
community and reduce Forest Service credibility to a new low.
cc: Dave Baumgartner
Tom Lyon
Dick Carter UWA
Steve Flint
Bruce Pendery Bridgerland Audubon
Rudy Lukez Utah Chapter, Sierra Club
, . ---
S tn+:erely, • -7
Jack T. Spence
Dept. of Chemistry
Utah State University
Logan, Ut 84322
,
tate 0 Samuel J. Taylor
Chai rman
Wayne S. Winters UTAH DEPARTMENT OF TRANSPORTATION Vice Chairman E. H. Findlay
Director
Gene Sturzenegger, P.E.
Assistant Director
H. H. Richardson, P.E.
Disl.ri cl Director
169 North Wall Avenue
P.O. Box 2747
Ogden. Utah 84404
To Whom It May Concern:
James G. Larkin
February 2, 19MaunCox
Todd G. Weston
Elva H. Anderson
Secretary
The attached document is an alternative for improvements to SR-89 in Logan
Canyon. Elements of the alternative have been carefully examined by
representatives of the UOOT, FHWA, and USFS. This document should not be
considered as a preferred alternative, nor as completely addressing impacts of
the suggested elements, but as one alternative of many possible alternatives.
If the environmental impact on an element by element, and total element basis
is acceptable, as analyzed in the environmental impact statement, then the
elements of this alternative should be pursued. This alternative will be
included in the Environmental Impact Statement.
Various groups may wish to meet with agency representatives to discuss this or
other improvement concepts. Arrangements can be made by contacting Lynn
Zollinger at 399-5921.
Richard Harris, P.E.
USFS, Forest Engineer
LRZljw/0924J
an equal opportunity employer
n Silver, P.E.
, Area Engineer
Sincerely yours,
n R. Zo lnger, P. E.
Preconstruction Engineer, 0-1
Dave BaUTIBa:r tner, District Ran er
U .. J . Fores t Service
860 N. 1200 r: .
Logan, UT 84321
Dear Dave:
655 Canyon Road
Logan, tIT 94321
January 17, 1989
Stew Flint provided Ire vlith a ooPY of tJ'1e "agency alternative"
on the Logan Canyon Jigrrway, and. I presume you might t:e interested in
having ccmnents on it.
The dOC1..ltmnt represent:.S no significant change frQ"ll tJDOT' ~' 1979
plans for Logan ('",,'lIlyon. It reflects absolutely none of the I.D. team' s
input, delivered in bA16nty-two meetings, each of several hoUrs' duration.
It reflects no environrrental consciotl."3ness at all, but i s Jasically an
en1]iI1eering statement. It makes the old, thoroughly discredited ar-,
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•
•
Editor, The Herald Journal
75 W 300 N
Logan, Utah 84321
Dear Sir:
January 22, 1988
As a member of the 10 team responsible for preparation of tech­nical
information for the Logan Canyon highway project EIS, I am
appalled at the recent decision by UDOT to pursue the maximum de­velopment
alternative.
If this alternative is implemented, most of the canyon from
Right Fork to Ricks Springs (as well as major sections of the up­per
canyon) will be severely affected. Much of the free running
river will be channeled within retaining walls, the river bed it­self
will be altered, the riparian zone (on which the wildlife
depends) will be destroyed, the fishing and water quality will
be degraded, the river will disappear beneath cantilever structures,
the lovely riv~rside rock ledges will by dynamited, huge cuts .
in the hillsides will be made, thousands of cubic yards of fill
will be dumped into side canyons, large amounts of conifer forest
and other vegetation will be bulldozed and Logan Canyon as we
now know it will be gone forever.
UDOT has made this decision in spite of the overwhelming pub­lic
opposition to this alternative expressed in the scoping meet­ings,
in spite of a legally binding Forest Service Plan which des­ignates
Logan Canyon as a scenic highway and prohibits the destruc­tion
consequent to the project, and in spite of the best efforts
of environmental representatives on the 10 team in endless meet­ings
over more than two years to achieve a reasonable compromise
which protects the canyon and also allows necessary improvements.
In fact, the UDOT decision prepresents a no compromise position,
essentially identical to their position in 1980. In short, UDOT.
in their incredible arrogance, has listened to no one and has
learned nothing. Two years or work and over $600,000 of taxpayers
money have been wasted. Preservation of the scenic beauty and the
environmental quality of Logan Canyon is of no apparent concern
to this public agency.
Many people have asked me what they can do to protect the can­yon.
Telephone calls and letters to James Naegle, Utah Department
of Transportation, 4501 South 2700 West, Salt Lake City, 84119
protesting the decision, and to Dave Baumgartner, U.S. Forest Ser­vice,
860 N 1200 E, Logan supporting the Forest Service Plan are
needed. Later, there will be an opportunity for both oral and
written comments when the DEIS is released. Additional infor­mation
may be obtained by calling 753-8548. Only a concerned
citizenry can preserve Logan Canyon from the mindless destruc-tion
planned for it by UDOT.
Jack T. Spence
361 Blvd
Logan, Ut 84321
-
•
Mr. James Naegle
Utah Department of Transportation
4501 So. 2700 West
Salt Lake City, Utah 84119
Dear Jim:
January 11, 1988
Thank you for your recent letter concerning my efforts in the
Logan Canyon DEIS study.
While I appreciate your comments, I find them inconsistent with
your actions. After spending the better part of two years attend­ing
meetings, reading documents, checking calculations, etc., I con­sider
it an insult not to be provided with a copy of the preliminary
DEIS. It cost us (Sierra Club, Audubon Society, Utah Wilderness
Association) $20.00 to duplicate the Forest Service copy, which I
understand was made available to us only reluctantly and at the in­sistence
of the Forest Service. So much for the good faith of UDOT.
I also wish to make some comments on the role of the 10 team
in this study. It was agreed early on that all technical memos
would be approved by the team. This has not been done. It was
my understanding the DEIS would be approved by the team. This is
clearly not to be done. Finally, it was also my understanding the
10 team would make recommendations concerning a preferred alter­native.
Again, this is clearly not to be done. I regard this as
a breach of faith by both UDOT and CH2M Hill.
The preliminary DEIS has several major problems:
1.The Spot Improvement Alternative must be considered as en­compassing
all 35 spot improvements. It is a violation of NEPA
requirements to present a shopping list, with UDOT selecting some
number of improvements from the list at a later date.
2.In view of this, there is no environmentally acceptable
alternative in the preliminary DEIS except No Action.
3.NEPA requirements have not been met with respect to a range
of alternatives. The Spot Improvement alternative with all 35
projects at the level described is essentially the same as Alter­native
C.
Unless our alternative (now in the Appendix), or a reasonably
similar alternative, is included as a legitimate alternative, we
will oppose all alternatives except No Action, or request that the
DEIS be rejected as not meeting NEPA requirements. Legal action
with respect to this request may also be pursued.
I regret the culmination of two years of effort has resulted
in this situation. The environmental representatives on the 10.
team have repeatedly tried to convince UDOT and CH2M Hill that
their concerns need serious attention. It is clear we have failed.
and the present situation must be regarded as adversary.
cc:Dale Bosworth
Dave Baumgartner
Lynn Zo 11 i nger
Stan Nuffer
UWA
Rudy Lukez, Sierra Club
Steve Flint, Audubon Society
Sincerely,
/;"1, ~--:
,"?? ,CI?;/ .
;
/ .
/ Jack T. Spence
v ' 361 Blvd.
Logan, Ut 84321
• • • I Izens or e ·ro ec Ion
o oan _an on
rh.J () ~ £ //-J r .
Wilson
Lcs+ -f,~ r Tc, /k.e..A fa J.. ~ ~ ~
From: Steve Flint ~~-k .:'5!/{e-J;
·~ e ...,
Of
F..nclosed are the ~errestrial Resources Technical Memorandum and
the biological assessment for Primula maguirei. This biological
assessment is referred to in the tech. memo as "Welsh 1987".
One of the most glaring faults of this tech. memo is the failure
to adequately discuss the disposal of waste material. Table 2 (p. 21)
lists a few locations (but does not address impacts), but does not
admit that these locations will only accolnodate a small portion of
the waste which the action alternatives will generate. CH2MHill's
refusal to discuss site-specific impacts contributes to this problem.
Table 1 (p. 18) shows the high percentage of the riparian zone
which would be impacted. Most of this impact would be retaining walls
at the edge of tl1e river, destroying all vegetation on one side of
the stream.
This document downplays the impacts on P. maguirei. One of our
concerns, which is not mentioned in this document, is the proposed
location of & slow vehicle turnout adjacent to population 4. We believe
this location is unacceptable as it would remove too much vegetation.
In addi tion, there is a "collection" danger: the primrose is attractive
1IIlhl?n it blooms in the sprine:. We fear people may not know of its
status and attempt to remove plants for their gardens. A related
problem is the display of papulation locations in Figure 1 (p. 8) •
We believe this is proprietary information which should not be included
in a document such a3 this which is available to the public. Much of it
is not even necessary for this study: populations 2 and 6 are outside
the study area, and population 3 is across the river from the highway.
The biological assessment dismisses the impacts to the primrose
by speculating on its physiologival performance. It should be pointed
out that nothing is known about the species' physiology; all the
speculation is based on its habitat. In addition, while the author
(Welsh) has considerable experience in taxonomy, I do not believe he
has much background in physiology.
Other tech. memos will follow shortly.
Note: Despite the fact CH2MHill had provided UDOT with a
draft of the EIS, they have not produced a final
version of the Terrestrial Resources tech. memo.
This June '37 version is the most recent draft.
p.o. box 3580 logan, ut 84321
•
• • -
Citizens for the Protection of Logan Canyon
P. O. Box 3451, Logan, Utah 84323 - 3451
April 5, 1995
Citizens for the Protection of Logan Canyon on
Thursday, March 30, 1995, filed a lawsuit against
Cache County and its County Council for not complying with the laws of the State of
Utah and the ordinances of Cache County when they issued a Special Permit to the
Westons permitting their sign in Wellsville Canyon. As an organization and as
individuals, CPLC has a long-standing interest in Cache County and its canyons. It is the
sentiment of the organization that permitting the sign, in direct violation of state and
county laws, set a dangerous precedent for Logan Canyon, as well as for all of the
canyons in the county.
Business signs are presently prohibited in Forest/Recreation Zones under the current
County Land Use Ordinances. Application for a Special Permit for the sign was first
submitted to the Cache County Planning Commission, which unanimously recommended
against the proposed sign because it was not in keeping with the Forest/Recreation Zone.
The Planning Commission suggested an alternative more in keeping with the Zone. The
County Council, which in the Ordinances has reserved to itself the final decision, granted
a Special Permit for the sign, which, in the meantime, had already been erected by the
Westons without a permit.
By filing this lawsuit, CPLC hopes to make certain that all county agencies follow legal
procedures when making decisions about public lands, including all canyons within
Forest/Recreation Zones.
CPLC could use your help in defraying the expenses of this lawsuit. If you have not sent
in your membership dues, please take this opportunity to do so. Or, if you are already a
member of CPLC, please consider making an additional contribution.
--------------------------------------------------------------------------------------------------------------------
please print legibly
CPLC MEMBERSHIP APPLICATION
Name Address ----------------------------- City State Zip Phone: Hom e ___ Work ___ _
Areas of Expertise/ Willingness to Volunteer __________________________________ Regular Member ($10) Student Member ($5)-:--_
I wish to make an additional contribution of: $10 $25 $50_ $100_
Other --
Send to: CPLC, P.O. Box 3451, Logan, UT 84323-3451
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Mr. David W. Berg P.E.
Chief Environmental Engineer
Utah Department of Transportation
4501 South 2700 West
Salt Lake City, UT 84119
Dear Mr. Berg:
Citizens for the Protection
of Logan Canyon
P.O. Box 3501
Logan, UT 84323
October 27, 1994
With our thanks to you personally for your willingness to hear our
case, and our appreciation for being included in the process of
modifying the Logan Canyon ROD, we wish to communicate our
provisional and conditional approval of the revised ROD. Specifically,
this approval refers to agreements between UDOT and representatives
of CPLC, arrived at in meetings taking place from December, 1993,
through October, 1994, as to what the final Logan Canyon ROD should
contain. We understand and accept the "quid pro quo" nature of those
negotiations, and the following represents the present CPLC position.
General Issues of Utmost Concern to CPLC:
(1) With the exception of the need for replacing bridges, CPLC is not
persuaded that the project's overall purpose and need have been
demonstrated.
(2) CPLC remains concerned with the accuracy and statistical reliability
of both traffic-flow and safety data collected by UDOT. Before CPLC
could agree to any accident-dependent curve-flattening (for example,
curve #5 in Section 1a), the organization, as part of the CAT team, would
need to study the data being presented.
(3) CPLC restates its deep concern for the protection of any and all
wetlands and riparian areas along the project route, and its concern for
the longterm disposition of these sites.
(4) CPLC restates its deep concern for the intactness of the visual and
aesthetic resources of Logan Canyon, and restates its support of the
Wasatch-Cache National Forest's Forest Plan of 1985, which states that
there shall be no degradation of the Canyon's visual resource.
•
•
CPLCIUDOT
October 27, 1994
p. 2
(5) CPLC strongly supports the hiring of an independent consultant, to
be actively engaged in the design and construction phases of the project,
and to have site-specific stop-work powers during construction. CPLC
strongly supports the preparation of a detailed monitoring plan by
UDOT, which will spell out the qualifications, independence, and range of
specific powers of the consultant and the consultant's team, and will
detail the frequency and length of time of on-site inspections.
Point-by-Point Discussion:
[The following are specific issues of demonstrated concern to CPLC
members. Other issues may arise during the project's design phase.]
A. Roadway Widths
(1) CPLC understands that the roadway width from the beginning
of Section 1 a to Lower Twin Bridge will be 26', and the roadway width
from Lower Twin Bridge to the end of Section 1b will be 34'.
(2) CPLC understands that the roadway width in the Lower
Upper Canyon -- specifically, from the cattle guard at Milepost 391.6 to
the Beaver Mountain turnoff -- will be 34'.
(3) CPLC remains concerned with the projected 40' roadway
width from Beaver Mountain turnoff to the Bear Lake Overlook.
B. Alignment
(1) CPLC continues to question the need for realignment of curves
in the project.
(2) CPLC strongly supports the present alignment for Curve #5 in
Section 1a.
(3) CPLC supports the proposed northern alignment for Curve #85.
C. Passing Lanes
(1) CPLC supports the use of slow-vehicle turnouts as preferable
to passing lanes, specifically through Section 2. CPLC remains concerned
with the number, location, and length of passing lanes proposed by
UDOT in Section 2.
D. Bridges
(1) CPLC understands that bridge replacement will the first
construction undertaken in the project.
'.
•• 0 ' , . •
E. Riprap and Retaining Walls
CPLCIUDOT
October 27, 1994
p. 3
(1) CPLC strongly supports minimizing all uses of riprap and
retaining walls. Natural banks should be retained wherever possible.
F. Location of the Batch Plant
(1) CPLC recognizes the complexity of environmental trade-offs
involved in the location of a batch plant for each specific phase of the
overall project. However, CPLC strongly supports the use of one batch
plant, located at the state equipment sheds, for all phases of the project.
G. Future Activity of CPLC
(1) CPLC looks forward to participating on the CAT team during
the design and construction phases.
(2) CPLC reserves its normal constitutional right to seek legal
redress in the event of noncompliance with the revised ROD, violation of
environmental law, or noncompliance with the 1985 Wasatch-Cache
Forest Plan. . ..
Mark Bowen
Nathan Hult
Thomas Lyon
--- - ----------
Sean Swaner
Sincerely,
The Steering Committee
Citizens for the Protection of Logan Canyon
Katherine Gilbert Christine Hult
Lauren Keller Ronald Lanner
Paul Packer Gordon Steinhoff
.' .'
Mr. David W. Berg P.E.
Chief Environmental Engineer
Utah Department of Transportation
4501 South 2700 West
Salt Lake City, UT 84119
Dear Mr. Berg:
Citizens for the Protection
of Logan Canyon
P.O. Box 3501
Logan, UT 84323
October 27, 1994
With our thanks to you personally for your willingness to hear our
case, and our appreciation for being included in the process of
modifying the Logan Canyon ROD, we wish to communicate our
provisional and conditional approval of the revised ROD. Specifically,
this approval refers to agreements between UDOT and representatives
of CPLC, arrived at in meetings taking place from December, 1993,
through October, 1994, as to what the final Logan Canyon ROD should
contain. We understand and accept the "quid pro quo" nature of those
negotiations, and the following represents the present CPLC position.
General Issues of Utmost Concern to CPLC:
(1) With the exception of the need for replacing bridges, CPLC is not
persuaded that the project's overall purpose and need have been
demonstrated.
(2) CPLC remains concerned with the accuracy and statistical reliability
of both traffic-flow and safety data collected by UDOT. Before CPLC
could agree to any accident-dependent curve-flattening (for example,
curve #5 in Section la), the organization, as part of the CAT team, would
need to study the data being presented.
(3) CPLC restates its deep concern for the protection of any and all
wetlands and riparian areas along the project route, and its concern for
the longterm disposition of these sites.
(4) CPLC restates its deep concern for the intactness of the visual and
aesthetic resources of Logan Canyon, and restates its support of the
Wasatch-Cache National Forest's Forest Plan of 1985, which states that
there shall be no degradation of the Canyon's visual resource.
. - -
CPLClUDOT
October 27, 1994
p. 2
(5) CPLC strongly supports the hiring of an independent consultant, to
be actively engaged in the design and construction phases of the project,
and to have site-specific stop-work powers during construction. CPLC
strongly supports the preparation of a detailed monitoring plan by
UDOT, which will spell out the qualifications, independence, and range of
specific powers of the consultant and the consultant's team, and will
detail the frequency and length of time of on-site inspections.
Point-by-Point Discussion:
[The following are specific issues of demonstrated concern to CPLC
members. Other issues may arise during the project's design phase.]
A. Roadway Widths
(1) CPLC understands that the roadway width from the beginning
of Section 1 a to Lower Twin Bridge will be 26', and the roadway width
from Lower Twin Bridge to the end of Section 1 b will be 34'.
(2) CPLC understands that the roadway width in the Lower
Upper Canyon -- specifically, from the cattle guard at Milepost 391.6 to
the Beaver Mountain turnoff -- will be 34'.
(3) CPLC remains concerned with the projected 40' roadway
width from Beaver Mountain turnoff to the Bear Lake Overlook.
B. Alignment
(1) CPLC continues to question the need for realignment of curves
in the project.
(2) CPLC strongly supports the present alignment for Curve #5 in
Section 1a.
(3) CPLC supports the proposed northern alignment for Curve #85.
C. Passing Lanes
(1) CPLC supports the use of slow-vehicle turnouts as preferable
to passing lanes, specifically through Section 2. CPLC remains concerned
with the number, location, and length of passing lanes proposed by
UDOT in Section 2.
D. Bridges
(1) CPLC understands that bridge replacement will the first
construction undertaken in the project.
•
E. Riprap and Retaining Walls
CPLCIUDOT
October 27, 1994
p. 3
(1) CPLC strongly supports minimizing all uses of riprap and
retaining walls. Natural banks should be retained wherever possible.
F. Location of the Batch Plant
(1) CPLC recognizes the complexity of environmental trade-offs
involved in the location of a batch plant for each specific phase of the
overall project. However, CPLC strongly supports the use of one batch
plant, located at the state equipment sheds, for all phases of the project.
G. Future Activity of CPLC
(1) CPLC looks forward to participating on the CAT team during
the design and construction phases.
(2) CPLC reserves its normal constitutional right to seek legal
redress in the event of noncompliance with the revised ROD, violation of
environmental law, or noncompliance with the 1985 Wasatch-Cache
Forest Plan. . --
Mark Bowen
Nathan Hult
Thomas Lyon
-- -- ---------
Sean Swaner
Sincerely,
The Steering Committee
Citizens for the Protection of Logan Canyon
Katherine Gilbert Christine Hult
Lauren Keller Ronald Lanner
Paul Packer Gordon Steinhoff
[DRAFT]
Mr. David W. Berg P.E.
Chief Environmental Engineer
Utah Department of Transportation
4501 South 2700 West
Salt Lake City, UT 84119
Dear Mr. Berg:
Citizens for the Protection
of Logan Canyon
P.O. Box 3501
Logan, UT 84323
October 20, 1994
With our thanks to you personally for your willingness to hear our
case, and our appreciation for being included in the process of
modifying the Logan Canyon ROD, we wish to communicate our
provisional and conditional approval of the revised ROD. Specifically,
this approval refers to agreements between UDOT and representatives
of CPLC, arrived at in meetings taking place from December, 1993,
through October, 1994, as to what the final Logan Canyon ROD should
contain. We understand and accept the "quid pro quo" nature of those
negotiations, and the following represents the present CPLC position.
General Issues of Utmost Concern to CPLC:
(1) CPLC is not persuaded that the project's overall purpose and need
have been demonstrated.
(2) CPLC remains concerned with the accuracy and statistical reliability
of both traffic-flow and safety data collected by UDOT. Before CPLC
could agree to any accident-dependent curveMflattening (for example,
IS iff ~edicni: 1a), the organization, as part of the CAT team, would
Hud "' "tidy the data being presented.
(~, ClYte testates its deep concern for the protection of any and all
\f,t1flnd8 tiiid riparian areas along the project route, and its concern for
th' imtgtefm disp()jition of these sites.
(4) CftLC restat~s its deep concern for the intactness of the visual and
ae~thede res911tc~~ of Logan Canyon, and restates its support of the
Wa§a·t~h-Ca£he National Foreses Forest Plan of 1985, which states that
there shall b~ no degradation of the Canyon's visual resource.
(5) CPLC stroftlly iiUppOtts the hiring of an independent consultant, to
be ~eHv"l)' enga86td ifi the design and construction phases of the project,
iUld to tUlve ~ite"specific stop .. work powers during construction.
Point-by-Point Discussion:
CPLC/UDOT
October 20, 1994
p.2
[The following are specific issues of demonstrated concern to CPLC
members. Other issues may arise during the project's design phase.]
A. Roadway Widths
(1) CPLC understands that the roadway width from the beginning
of Section 1 a to Lower Twin Bridge will be 26', and the roadway width
from Lower Twin Bridge to the end of Section 1 b will be 34'.
(2) CPLC understands that the roadway width in the Lower
Upper Canyon -- specifically, from the cattle guard at Milepost 391.6 to
the Beaver Mountain turnoff -- will be 34'.
(3) CPLC remains concerned with the projected 40' roadway
width from Beaver Mountain turnoff to the Bear Lake Overlook.
B. Alignment
(1) CPLC strongly supports the present alignment for Curve #5 in
Section 1a.
(2) CPLC supports the proposed northern alignment for Curve
#85.
(3) CPLC continues to question the need for realignment of curves
in the project.
C. Passing Lanes
(1) CPLC supports the use of slow-vehicle turnouts as preferable
to passing lanes, specifically through Section 2. CPLC remains concerned
with the number, location, and length of passing lanes proposed by
UDOT in Section 2.
D. Riprap and Retaining Walls
(1) CPLC strongly supports minimizing all uses of riprap and
retaining walls. Natural banks should be retained wherever possible.
E. Location of the Batch Plant
". (1) CPLC recognizes the complexity of environmental trade-offs
involved in " the location of a batch plant for each specific phase of the
overall project. However, CPLC strongly supports the use of one batch
plant, located at the state equipment sheds, for all phases of the project.
F. Future Activity of CPLC
CPLCIUDOT
October 20, 1994
p. 3
(1) CPLC looks forward to participating on the CAT team during
the design and construction phases.
(2) CPLC reserves its normal constitutional right to seek legal
redress in the event of noncompliance with the revised ROD, violation of
environmental law, or noncompliance with the 1985 Wasatch-Cache
Forest Plan.
[signed]
Peter W. Karp
Forest Superv•l sor
Wasatch-Cache National Forest
Mr. Karp,
We are writing to you to request a rev iew of a previous
decision by the Wasatch-Cache National Forest. Recently, you
ammended the Wasatch-Cache National Forest Land and Resource
Ma¢hagement Plan to provide interim protection to the Stillwater
Fork for possible inclusion in the nation's Wild And Scenic River
System.
It is our opinion that both we and your River Inventory Team
believe that at least one river segment on the Cache National
Forest, and probably two, should be eligible as a "recreational"
river under the national Wild and Scenic Rivers Act. These
segments are the Logan River (Lower Twin Bridge to Beaver Ck.)
and the Right Hand Fork of the Logan River. There is currently a
proposed improvement of u.S. 89 by the Utah Department of
Transportation (UDOT). The proposed improvement might harm the
river's flee-flowing nature. Therefore it is important to
consider the Logan River (Lower Twin Bridge to Beaver Creek) now,
before said construction takes place.
We have evaluated this segment o f the Logan and found it is
free-flowing and outstandingly remarkable (see attached
documents). Your wild and Scenic River Inventory Team appears to
agree with us on the latter point. Consult Appendix D of the
recently amended Forest Plan. You will find that the
Identification Team (IDT) found this segment might possess
outstandingly remarkable characterists in five (5) categories.
The IDT found the Stillwater Fork, which you set aside for
interim protection, might possess outstandingly r emarkable
characteristics in only one category.
The problem may be that the IDT did not conside r the segment
free from roads because the Scenic Byway, U.S. 89, parallels the
river along this segment. However, we would call your attention
to the section of the Wild and Scenic Rivers Act for assessing
the free-flowing nature of a recreational river, it states,
"roads may parallel the river for much of its length as long as
much of the road is unobtrusive or well-screened."
We request that you and your Identification Team reconsider
this segment of the Logan. We would prefer assessments of the
Logan from the source to Beaver Ck., Lower Twin Bridge to Beaver
Ck., the Right Hand Fork of the Logan R., and Beaver Ck. (source
to Logan R.). We believe all of these segments may qualify as
recreational rivers under the national Wild and Scenic Rivers
Act.
Sincerely,
Citizens for the
Protection of
Logan Canyon
Mr. Stan "luffer
CH 2
M I-'ill
Box 8748
Boise, ID 83707
Dear Stan:
655 Canyon Road
Logan, UT 84321
June 23, 1987
First, thank you for this opportunity to comment on the drafts
of the technical memoranda and alternatives for the Logan Canyon DEIS.
I consider this a genuine opportunity to (possibly) save a great deal
•
of many people's time and energy. If the DEIS reflects these memoranda,
in content and bias, I think I can assure you there will be an extremely
strong public protest.
As was mentioned yesterday at the meeting in Brigham City, the chief
problem with the memoranda, with the exception of the one on aquatic
resources~ is their very obvious bias toward a major road project. For
example, the socioeconomic memo devotes many pages to the dependence of
Rich County upon Logan for various goods and services. The clear thesis
of this document is that an "improved" road through Logan Canyon is vital
to Rich County':s continued life and to its future development--at one point
even industrial development is mentioned as a future possibility for Rich
County, on the assumption that an "improved" Logan Canyon highway would
make such a thing possible. The fact is that Rich County exists and has
existed without serious hindrance caused by the two-minutes-slower Logan
Canyon highway of the present. The assumption that some kind of industrial
development would be good for Rich County is rank speculation, and judging
from the experience of ' places like Evanston and Rock Springs, is untrue.
But to set this kind of chamber-of-commerce dreaminess forth as a real
item of probability, in a technical memo, is nonsense.
It is also highly biased. We are all aware of the number and strength
of the comments given at the Logan scoping meeting. But these comments DO
NOT APPEAR IN ANY FORM AND ARE NOT REFERENCED ANYWHERE in the documents
supplied so far. They have been completely ignored. The memo on visual
resources is a strange effort to quantify perception and aesthetics, and
results only in fragmenting and obfuscating the real situation into a bunch
of numbers. The fact is that the natural appearance of Logan Canyon is,
along with the ecological health of the river, the absolute primary matter
in hand. I can assure you that perception and the aesthetic sense are not
satisfied by numbers--they are based in an entirely different mode of
awareness.
This brings me to what may be the central problem in documents of this
nature. They attempt to state qualitative issues in quantitative terms.
A wise man once said that to do this is like judging the "Mona Lisa" by
weighing the paint. In the present documents, it is blithely stated that
if native trout are killed by construction, well then we can plant some
Stan Nu ffer
June 23, 1987
page 2
hatchery rainbows "to supplement angler catch rates," [po 38] and everything
will presumably be all right. But this is not so. There is a very great and
widely perceived difference between fishing for wild trout and fishing for
stocked trout; as a matter of fact, this very difference is the basis for the
Logan River's attractiveness as a qual tty trout stream. And it is a primary
reason for the Logan River's being a "million-dollar" fishery. This difference
between quality and quantity cannot be mitigated. It is a basic fact of
existence.
In the same way, you cannot mitigate a road-cut across a hillside. It is
simply there, and it destroys the wholeness of the scene which arouses the
qualitative sense of beauty. This is what the people in the Logan scoping
meeting were trying to say, one after the other. The issues are beauty and
wholeness. You can't fragment these things into a bunch of numbers and expect
people to be satisfied, just as you can't substitute a flabby hatchery fish,
raised on food pellets and habituated to a looming human figure bringing food,
for a wild and wary trout in a natural stream.
The documents presented so far clearly indicate that none of the alternatives
preserves Logan Canyon. "Spot Improvements" was supported by a number of
people at the Logan meeting, including mysel f; but now "Spot Improvements" has
ballooned into a major realignment of the highway in several crucial and
environmentally sensitive sections, and cannot be supported any longer. It
is decidely misleading, and even deceptive, to place "Spot Improvements" next
to "No Action," because it is emphatically not the second-least-damaging
alternative. .
The documents presented so far are biased individually and in the
aggregate. For just one example, "Aquatic Resources" mentions millions of
dollars being spent on the Logan River by fishermen, but this money somehow
does not appear in the socioeconomic memo. Why not? (If we get down to arguing
dollars and cents, which again is not the central issue here, I wonder if all
the alleged Rich County dependence on Logan amounts to a sum comparable to that
spent by Logan River fishermen.) For another example, which appears again and
again throughout the documents, it is alleged that the present highway is unsafe
and that flatter curves and higher speeds would be safer. No documentation for
this assumption is ever presented, and my conclusion is that if there were any
such documentation in existence, it would have been brought forward very
prominently by now. I doubt that a wider, faster, flatter-curved road is any
safer than a narrow, slow, curvy one. People adjust their speed to the circum­stances.
Logan Canyon is a canyon; it cannot be made into something other than
a canyon. If there is a road in it, it will need to be a narrow and winding
road and people will have to drive at slower speeds on it. That's IF the
intactness and beauty of the canyon are to be saved.
I realize that your firm has spent a good deal of time and work on this
matter, and so I hesitate to say the following. But it is clear that the entire
set of documents needs to be redone and written without bias. The "Alternatives"
chapter is so biased as to be for all intents and purposes worthless; it too
needs to be entirely redone. "Spot Imp IOvements" in particular is a travesty.
Sincerely yours,
rhvmAA
Thomas J. Lyon